TRAVANCORE RUBBER & TEA CO. LTD. & ANR. vs STATE OF KERALA & ANR.

The Supreme Court upheld the validity of Explanation 2 to Section 5 of the Agricultural Income Tax (Amendment) Act, 1961, which disallows deductions for expenses on immature rubber plants. The Court ruled that the State Legislature has the authority to define agricultural income and determine allowable deductions, affirming that the term 'income' encompasses a broad interpretation. Furthermore, the Court found that the provision does not violate Article 14 of the Constitution, as the distinction between rubber and tea plantations is justified based on their differing income derivation methods.